Supporting our borrowers.
As a responsible, regulated lender, we’re committed to delivering good outcomes for our borrowers.
Vulnerable customers
What is a Vulnerable Customer?
The FCA defines a vulnerable customer as ‘someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care’.
Customer Vulnerability – the landscape
In the results of their Financial Lives 2020 Survey, the FCA concluded that there were 24 million UK consumers that showed one or more characteristics of vulnerability.
Customer Vulnerabilities – key drivers
Each customer’s circumstances and vulnerabilities may be different. Whether it’s because of a life event, health condition, resilience or capability, vulnerabilities vary from customer to customer. Some vulnerabilities can be temporary, whilst others permanent.
Key drivers for characteristics of Vulnerability
| HEALTH | Health conditions or illnesses that affect ability to carry out day-to-day tasks |
| LIFE EVENTS | Life events such as bereavement, job loss, or relationship breakdown |
| RESILIENCE | Low ability to withstand financial or emotional shocks |
| CAPABILITY | Low capability in other relevant areas such as literacy or digital skills |
Vulnerability is complex and there can be multiple vulnerabilities at any one time. For example, someone with a disability may have recently been made redundant.
How to identify potential vulnerabilities?
The FCA’s BRUCE framework can help identify potential customer vulnerabilities:
| Behaviour | Do you notice any cues in your customer’s speech and behaviour? Do they have difficulty speaking clearly, repeat themselves, or show signs of becoming easily agitated? |
| Remembering | Are there any signs that the customer may have memory or recall issues? Do they take long pauses before responding, avoid answering questions directly, or try to change the subject? |
| Understanding | Are there any signs that the customer is having difficulty understanding the information? Watch out for signs like confusion in their responses, excessive agreement, or saying yes when it doesn’t seem right. |
| Communication | Can the customer express their thoughts, decisions, and questions clearly? Do they need a third party to assist with communication? |
| Evaluation | Is the customer having trouble weighing up all the information? Are they evaluating the advantages and disadvantages of each option? Are they overly dependent on one source of information? |
Supporting vulnerability
Customers who are vulnerable might find it harder to make sound decisions. It’s important that every customer receives a good outcome.
How can you help?
Once you’ve identified that a customer requires additional support:
- Check they’re happy to discuss the situation in more detail.
- Agree how best to move forward together with a communication and contact plan, if relevant.
- Be empathetic and support them with solutions that are appropriate to their individual circumstances.
- Explain what third-parties could be available to offer specialist support.
- Make sure they understand what’s been discussed and don’t be afraid to change your delivery style to suit your customer’s needs, if required.
- Check in with them – make sure that they’re happy with how the meeting is going.
- You can also signpost your client to external specialist support (Age UK, StepChange, MoneyHelper, Turn2Us, Mind, Samaritans).
Declaring a customer’s vulnerability to us
If you have a vulnerable customer and they’re happy for you to share with us (this is important – they need to consent to share the information), please let us know by contacting our Intermediary Team on 0330 123 1073 at any stage of the mortgage journey.
We’ll add a flag to the account so that if a customer contacts us directly, they won’t need to mention it again – this will help us make sure we give the right support.
The vulnerability flag can be edited or removed at any time – the customer just needs to notify us if the vulnerability changes or is no longer present.
Bereavement support
We realise that when someone dies it is a very emotional time for everyone, and it can be overwhelming. To ensure we support your customers in the best possible way, we’d encourage them to reach out to our team. They can be contacted on 01473 278511. We can then assess their circumstances and guide them on the next steps.
Payment difficulties
If your customers are worrying about how to pay their mortgage, please speak to us so we can help. Often, we’re able to agree a solution with our mortgage borrowers to help ease the burden, before it escalates into a bigger issue.
We’ve signed the Mortgage Charter – a set of standards agreed by the government, major lenders, and the FCA to support borrowers. We can have a discussion with your customers about their possible options under the Mortgage Charter and other options we can consider, depending on individual circumstances.
We have a dedicated page for customers experiencing problems paying their mortgages. Please feel free to direct your customers here.